Public Comment

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Name: SSAC Staff
Date:18 Jul 2023
Affiliation: Security and Stability Advisory Committee (SSAC)
Other Comments

On behalf of the SSAC, please find SSAC2023-14: SSAC Public Comment on Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations.

Summary of Attachment

SSAC2023-14 provides comments from the ICANN Security and Stability Advisory Committee (SSAC) on the Amendments to the Base gTLD RA and RAA to Modify DNS Abuse Contract Obligations. The SSAC thanks the Contracted Party House Negotiating Team for its work producing the proposed amendments.

Summary of Submission

The SSAC wishes to thank and commend the contracted parties and ICANN org staff for their initiative and efforts to address DNS Abuse by updating relevant contracts to include enforceable provisions and obligations for contracted parties. We look forward to seeing them implemented and further evolved over time. The SSAC provides three comments to the proposed amendments:

1) The SSAC strongly supports the goal to enhance obligations against DNS Abuse. They emphasize the need for diligent implementation, data collection, and reporting to measure progress and ensure success. They request regular updates from ICANN Org on the implementation and progress measurement.

2) The SSAC clarifies that the definition of DNS Abuse in the proposed language is not their own but a compilation from multiple sources for discussion purposes. They emphasize that the definitions used may be limited and not endorsed by the SSAC, and they may not cover all forms of abuse and evolving cybercrime.

3) The SSAC highlights an internal inconsistency in the proposed contractual language regarding the definition of spam. This could lead to confusion as the new language defines spam in two different ways.